Record Retention Question
So..... we keep any documentation relating to food safety implications for the shelf life of the product +1 year.
We do not have cited on our policy about the length of retention for other "non-food safety" documentation/ records. (ex. Sanitation task sheets - completed daily) or (Internal Audits forms - Completed on a yearly schedule)
Does anyone know of any legislation regarding the topic so that I know what the requirement is?
Is there a requirement? Anyone have any suggestions? Do a R/A ?
For SQF, we keep all paperwork for 2 years, or since the beginning of a new SQF program The paperwork for any item involved in a recall would be kept for 10 years.
We are under BRC - are there any regs that suggest this?
FDA requires 3 years
21CFR1403.42
21CFR1403.42.png 35.22KB 8 downloads
But as always it depends what product you're making. I don't know how many years they require for Fogurt.
For seafood fresh they require one year for frozen seafood they require two years (according to Fish and Fishery Products Hazards and Control Guidance 4th Ed.) which was made by the FDA, so it all depends on your product.
BRC is minimum shelf life of product + 1 year.
We pack for ASDA so keep everything for 6!!
Caz x
From a Food Safety Modernization Act (FSMA) FAQ:
IC.1.3 For how long are records required under the new law’s “Hazard Analysis and Risk-Based Preventive Controls” provision (FSMA §103/FDCA §418) required to be kept?
This section of the new law contains a provision (FDCA §418(g)) requiring that certain records established under that section be kept for at least 2 years.
Marshall
Thanks everyone! That helps
Something I didn't see mentioned was the paperwork associated with product that was involved in a recall. I have always been told keep those essentially forever for legal reasons. FDA regs always trump food safety certification requirements so I have always gone by those unless the food safety cert is more stringent.
BRC and IFS require shelf life + one year.
please take also in mind the intermediate shelf life and raw material shelf life.
E.g. if you are making intermediates, store them in freezer for 1/2 year and then using them in your products which has 1 year shelf life. The retention time of your records should include intermediate shelf life and should not be 2 years but at least 2,5 years. The information of the product in the markt need to be retain 1 year after shelf life of the products.
Also if you are making products with raw materials with long shelf life, you should take this into account. Just to make sure that you have the incoming good inspections and traceability records of these materials for the shelf life of your finished products + 1 year.
The Irish guideline ( FSAI) for food recall is a very useful tool and it gives a scientifically acceptable way of record retention time for each food product category.
YAY...we have done something right!!